less of payer. Individual clinicians that report Quality measure
data via claims need to report data on 60 percent of Medicare
beneficiaries only for the year. The claims data reporting option
is only available to individual clinicians, not groups.

Qualifying CEHRT Versions; Caring for Complex Patients

The use of both the 2014 and 2015 Edition Certified EHR Technologies (CEHRT) will qualify for ACI category reporting in
2018. However, all practices will need to use 2015 CEHRT in
2019, according to the 2018 QPP Final Rule. Practices that use
2015 Edition CEHRT for a continuous 90-day or longer period in

2018 will receive a 10 percent bonus in the ACI category.

CMS will award up to five bonus points for practices that care
for complex patients. The determination of complexity will be
based on the Hierarchal Condition Classification (HCC) coding
and the percentage of dual-eligible (Medicaid and Medicare)
patients cared for by the practice.

Small Practices

A small practice bonus will be available for the 2018 performance year. Small practices, defined as groups of 15 or fewer
eligible clinicians, will qualify for a small practice bonus of five
points. This will be added to the practice’s total MIPS score.

Small practices will be awarded a minimum of three points for
quality measures that do not meet data completeness requirements. Larger practices of 16 or more eligible clinicians will receive scores of one point for Quality measures that do not meet
data completeness requirements.

Small practices may be awarded hardship exemptions for the
ACI category. Small practices that face significant technology challenges, such as a lack of access to internet connectivity, may apply
for a hardship exemption for the ACI performance category.

Virtual Groups

Virtual groups have been approved for the 2018 and later performance years. Practices made up of between one and 10 eligible clinicians, based on Taxable Identification Numbers (TINs),
may join to form virtual groups. The group must form independently and all clinicians must explicitly state they are members
of the group via a formal written agreement. Each virtual group
will aggregate data in the Quality, ACI, and Improvement activities categories and submit this data to CMS through an approved reporting mechanism such as a certified clinical registry.

For the 2018 performance year the registration deadline for virtual
groups was December 31, 2017. Practices that wish to form virtual
groups in future years must register by December 1st of the year preceding the corresponding performance year. Practices are required
to commit to being part of a virtual group for the full performance
year. All members of a virtual group receive the same MIPS score and
payment adjustment. The only exceptions are clinicians participating in CMS-recognized APMs, including MIPS APMS and Qualifying
Participants in Advanced APMs. MIPS APM participants will receive
a MIPS score based on the APM scoring standard. Qualifying Advanced APM Participants are exempt from the MIPS.

There is no limit on the number of eligible clinicians that can
be in a single virtual group as long as the maximum number of
eligible clinicians in each TIN does not exceed 10. However, virtual groups whose total membership exceeds the small practice
eligible clinician maximum of 15 clinicians will not be eligible
for the five-point small practice bonus.

Hardship Exemptions for Uncontrollable Circumstances

MIPS-eligible clinicians that were impacted by extreme and uncontrollable circumstances such as hurricanes and other natural
disasters or public health emergencies may be awarded a hardship